Mary C. Smith v. UHS of Lakeside, Inc.
439 S.W.3d 303
| Tenn. | 2014Background
- James B. Smith was found confused and delusional and taken to a Lakeside-operated triage center for an involuntary psychiatric evaluation; he remained there ~49 hours before transfer to St. Francis where he was diagnosed with viral encephalitis and later died.
- Mrs. Smith sued Lakeside and others alleging medical negligence/health-care liability, EMTALA violations, false imprisonment, intentional and negligent infliction of emotional distress, and related claims; multiple amended complaints and motions followed.
- Lakeside filed multiple summary-judgment motions; after several hearings the trial court announced rulings from the bench but did not state the legal grounds for many grants of summary judgment and instructed counsel (Lakeside’s) to draft detailed orders stating the rationale.
- The trial court signed orders prepared largely verbatim by Lakeside’s counsel over the widow’s objections; those orders contained detailed factual and legal rationales that were not articulated by the court at hearing.
- The Court of Appeals vacated the orders for noncompliance with Tenn. R. Civ. P. 56.04 (trial court must state legal grounds for grant/denial in its order) and remanded; the Tennessee Supreme Court affirmed, holding the record shows the orders were not the product of the trial court’s independent judgment and Rule 56.04 was violated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the trial court comply with Tenn. R. Civ. P. 56.04 (must state legal grounds in order)? | Smith: Court failed to state grounds before adopting counsel’s draft; Rule 56.04 requires the court’s own stated grounds. | Lakeside: Signed orders are the court’s final statement; grounds in those orders should be imputed to the court. | Held: Court violated Rule 56.04; trial court must state grounds before requesting prevailing party to draft order. |
| May a trial court adopt orders prepared by prevailing counsel? | Smith: Adoption is improper when the record shows the court did not independently state its reasons; risk of counsel-driven rationale. | Lakeside: Routine practice; permissible and orders signed by judge reflect court’s ruling. | Held: Permissible in principle, but only if the order reflects the court’s independent judgment and record shows the court’s own grounds. |
| Can reasons in a counsel-drafted order be attributed to the court when not stated on the record? | Smith: No; reverse-engineering rationale from counsel’s draft is impermissible. | Lakeside: Yes; the court’s signature makes the document the court’s statement. | Held: No; where the record shows the court left rationale to counsel, reasons cannot be imputed to the court. |
| Remedy for Rule 56.04 violation here? | Smith: Vacate the challenged summary-judgment orders and remand. | Lakeside: Orders should stand or be remanded for limited clarification. | Held: Vacated the orders and remanded for further proceedings; Lakeside may renew motions on remand. |
Key Cases Cited
- Anderson v. City of Bessemer City, N.C., 470 U.S. 564 (1985) (criticized verbatim adoption of party-prepared findings and emphasized the need for records showing the judge’s own considered conclusions)
- Delevan-Delta Corp. v. Roberts, 611 S.W.2d 51 (Tenn. 1981) (trial courts may permit counsel to submit proposed findings, but independent judge-prepared findings are preferable)
- Morgan Keegan & Co. v. Smythe, 401 S.W.3d 595 (Tenn. 2013) (courts speak through their orders; orders should reflect judicial action)
- Summers v. Thompson, 764 S.W.2d 182 (Tenn. 1988) (judge must apply law to facts and exercise independent judicial function)